Investors engaged in overseas investment have been closely watching the National Development and Reform Commission’s ("NDRC") Measures for Administration of Overseas Investments by Enterprises ("Order 11") since its effectiveness on March 1, 2018. To coordinate the implementation of Order 11, NDRC has promulgated Circular of the National Development and Reform Commission on Issuing the Catalog for Overseas Investment in Sensitive Industries (Fa Gai Wai Zi [2018] No.251, "Sensitive Industries List") and Circular of the National Development and Reform Commission on Issuing Standard Forms in Support of the Measures for Administration of Overseas Investments by Enterprises (2018 Edition) (Fa Gai Wai Zi [2018] No. 252 "Standard Forms"). Despite this regulatory guidance, however, investors still face many issues regarding how Order 11 is to be implemented and interpreted, such as the specific scope of sensitive industries, NDRC review standards for approving overseas investments in sensitive industries, and whether Order 11 approval is required when the overseas investment funds are entirely sourced from outside of China.